The CMBS Compliance Director reports to the Managing Director and is responsible for developing, instituting, overseeing and executing processes that ensure and promote compliance within the CMBS Servicing & Asset Management activities of the Company. The Director provides senior management with a basis for measuring and assessing the Company’s effectiveness in maintaining compliance with regulations, legislation, contractual (PSA) requirements, and internal policies and guidelines.
- Is responsible for ensuring that the CMBS Servicing & Asset Management activities of the company are compliant with all applicable laws, regulations, contractual obligations, and internal policies and procedures.
- Oversees and orchestrates the daily and administrative activities of the CMBS Compliance Department, including management, training and assessment of department staff.
- Oversees and contributes to the design of Company processes, policies and procedures, ensuring established processes contain appropriate controls that facilitate CMBS compliance with legal and contractual requirements.
- Proactively and effectively interacts with various departments within the organization to coordinate CMBS compliance process implementation and address inter-department issues.
- Designs, completes, and reviews test work performed in specific areas of the Company, including reports and templates, to periodically assess CMBS compliance with regulations, contractual requirements, and Company policies and procedures.
- Disseminates CMBS regulatory and contractual compliance requirements, raising awareness and facilitating training relevant to each team’s specific areas of responsibility (i.e. process walkthroughs for training purposes).
- Manages the review and abstracting process for various types of contracts, including securitization and pooling and servicing agreements, in order to ensure all key requirements are properly identified and highlighted.
- Reviews and approves Asset Approval Memoranda for CMBS Non-Transfer consents and loan workout proposals to ensure that Company’s policies and contractual requirements, including PSA, Co-Lender, and Inter-creditor Agreements requirements, are identified and highlighted to the Asset Manager prior to the point of closing or final loan resolution.
- Monitors transactions and performs reviews of specific CMBS activities to ensure compliance with REMIC restrictions and Reg AB Servicing Criteria.
- Prepares and coordinates delivery of the Company’s Annual Compliance certifications
- Contributes to the preparation of presentation and review materials for rating agencies, trust advisors and other external entities.
- Manages and coordinates the annual Regulation AB audit engagement with the external auditors.
- Heavy experience (10+ years) in law, securities, compliance and/or audit with exposure to CMBS is required.
- JD Degree is required.
- Deep knowledge of Pooling and Servicing Agreement structures and PSA general requirements or similar securitized structures and agreements is required.
- Knowledge of and experience with CREFC requirements and guidelines is preferred.
- Additional knowledge of contract and loan documentation review, including the preparation of abstracts of complex legal documents/contracts is desirable.